2016年-IMF国际货币组织全球_Russian_Federation_Financial_Sector_Assessment_Program_Technical_Note_51页_763kb

Summary of the Russian Federation's Bank Resolution and Crisis Management Framework

Core Content

This document provides an analysis of the Russian Federation's bank resolution and crisis management framework, focusing on institutional structure, crisis preparedness, early intervention, resolution triggers, crisis management tools, and funding mechanisms. It is part of the Financial Sector Assessment Program (FSAP) conducted by the International Monetary Fund (IMF) and the World Bank in 2016, with the aim of improving the effectiveness of the resolution framework and reducing reliance on public funds.

Main Recommendations

Institutional Framework

A. Institutional Setting

• The Central Bank of the Russian Federation (CBR) is the decision-making authority for bank supervision and resolution.
• The Deposit Insurance Agency (DIA) has veto power over resolution measures involving its participation, such as open bank resolution or purchase and assumption (P&A) transactions.
• The CBR is responsible for appointing a provisional administrator and overseeing resolution measures with DIA participation.
• The DIA handles operational aspects of open bank resolution and P&A transactions, and acts as a bankruptcy receiver or liquidator when the failed bank was licensed to take deposits from individuals.

B. Domestic Coordination and Cooperation

• The National Council on Ensuring Financial Stability (FSC) serves as a high-level interagency advisory board for financial stability-related measures.
• The FSC was strengthened in 2015 with a broader membership and has been effective in interagency coordination.
• The CBR and DIA are required to comply with the FSC's recommendations under the "comply or explain" rule.

C. Cross-Border Coordination and Cooperation

• The resolution framework should be improved to enhance cooperation with foreign resolution authorities.
• This includes strengthening information exchange and sanctioning powers for failed banks' managers.

Crisis Preparedness

A. Financial Stability Assessment and Contingency Planning

• The CBR has been tasked with conducting financial stability assessments and contingency planning.
• The framework should be expanded to include a broader range of resolution powers and safeguards.

B. Strengthening Banks' Loss Absorption Capacity

• A comprehensive review of banks' asset portfolios and collateral valuations is recommended to ensure adequate capitalization.
• The transparency of asset quality has suffered due to the prolonged recession and forbearance measures.

C. Recovery and Resolution Planning

• Recovery plans should be mandatory for all banks, especially those of federal or regional importance.
• Legal amendments are necessary to allow the CBR to require banks to adopt resolvability measures.

Early Intervention and Resolution Triggers

A. Early Intervention

• A transparent early intervention framework should be adopted to identify and address financial weaknesses early.
• This includes defining mandatory and discretionary supervisory measures.

B. Triggers for Entry into Resolution

• Resolution triggers should be based on non-viability rather than full insolvency.
• This would allow the use of resolution powers before a bank becomes balance-sheet insolvent and before all equity is wiped out.

Crisis Management

A. Scope of Resolution Regime

• The resolution regime should be expanded to include bank holding companies.
• The CBR's powers should be broadened to facilitate mergers, recapitalization, and business transfers while ensuring continuity of critical functions.

B. Resolution Powers and Safeguards

• The framework should include the full range of resolution powers and safeguards recommended by the FSB KAs.
• Key changes include removing financing constraints, increasing flexibility in determining liabilities to be transferred, and using fair value for asset transfers.
• Statutory bail-in should be revisited, with consideration of financial stability implications and legal risks.

C. Bank Bankruptcy and Liquidation Proceedings

• Bankruptcy and liquidation proceedings should be made faster and more timely.
• The coverage of deposit insurance should be expanded to include deposits of non-related party corporate entities.

Safety Net and Resolution Funding

A. Emergency Liquidity Assistance (ELA)

• An ELA framework should be established to provide liquidity support during crises.
• This would reduce the reliance on public funds for resolution measures.

B. Funding Firms in Resolution

• The current funding arrangement for the DIA exposes it to substantial credit risk.
• The DIA should be allowed to fund resolution measures without resorting to public funds.
• The CBR should be authorized to provide loans to the DIA, but with federal indemnity if necessary.

C. Deposit Insurance Scheme

• The deposit insurance scheme should be expanded to cover corporate deposits.
• A two-tiered depositor preference rule should be introduced to protect depositors.

D. Depositor Preference

• A two-tiered depositor preference rule is recommended to reduce the total need for public funding.
• This would prioritize the protection of depositors while ensuring that creditors bear some losses.

Key Information

• Since January 2014, 28 banks were put into open bank resolution, with public funds amounting to 1 percent of GDP.
• The CBR revoked the licenses of 214 credit institutions, resulting in deposit insurance payouts of 0.8 percent of GDP.
• P&A transactions have only been used in three cases, indicating a limited use of this resolution tool.
• The DIA currently relies on CBR loans for funding, which is a quasi-fiscal activity.
• The decision-making process for resolution measures involving DIA participation should be reviewed to eliminate the DIA's veto power and allow the CBR to make decisions in consultation with the MoF and DIA, provided the least-cost test or systemic necessity is met.
• The CBR and DIA should be legally protected to ensure timely and effective resolution actions.
• The use of public funds should be minimized by introducing bail-in mechanisms and increasing the flexibility in resolution tools.